Nielsen, et al., No. 18-cv-01554 (N.D. Cal. Oct. 3, 2018). As a result of the preliminary injunction, TPS designations of Sudan, Nicaragua, Haiti, and El Salvador remain in effect (as of July 30, 2019). See Update on Ramos v. Nielsen, USCIS, https://www.uscis.gov/update-ramos-v-nielsen. 353. Constitution of Haiti, art. 11-12 (1987), http://pdba. georgetown.edu/Constitutions/Haiti/haiti1987.html. 354. Constitute Project, Haiti 1987 (rev. 2012), https:// www.constituteproject.org/constitution/Haiti_2012. 355. Id. 356. Immigration and Refugee Board of Canada, Haiti: Dual citizenship, including legislation; requirements and procedures for former Haitian citizens to re-acquire citizenship, HTI104293.E (Feb. 8, 2013), https://www. refworld.org/docid/51dd18df4.html. com/2017/12/23/us/politics/trump-immigration.html?_ r=0. 364. Migration Policy Institute, RAD Diaspora Profile, The Nigerian Diaspora in the United States, Migration Policy Institute (June 2015 rev.), https://www.migrationpolicy. org/sites/default/files/publications/RAD-Nigeria.pdf (as of June 2015, Nigerians were more likely to be naturalized U.S. citizens than the overall U.S. foreign-born population: 52% of Nigerians vs 44% of the U.S. foreign-born population. In light of the fact that half of Nigerian immigrants arrived in the United States in 2000 or later, their relatively high naturalization rate suggests that many Nigerian immigrants applied for U.S. citizenship shortly after they became eligible). 365. In other words, immediately and without delay at the time that such registered—or naturalized—citizen acquires the additional foreign citizenship. 357. United States Department of State, Bureau of Democracy, Human Rights and Labor, Country Reports on Human Rights Practices for 2011 – Haiti (2012), https:// www.state.gov/j/drl/rls/hrrpt/2011humanrightsreport/ index.htm#wrapper. 366. Const., art. 28(1) (1999) (Nigeria), http://www. nigeria-law.org/ConstitutionOfTheFederalRepublicOfNigeria.htm. 358. United States Department of State, Bureau of Democracy, Human Rights and Labor, Country Reports on Human Rights Practices for 2015 – Haiti (2016), https://2009-2017.state.gov/j/drl/rls/hrrpt/humanrightsreport/index.htm#wrapper. 368. Klapprott v. United States, 335 U.S. 601, 616–17 (1949). 359. Response by the Ministry of Foreign Affairs of Haiti conveying the position of the Haitian government in respect of the ruling (TC/0168/13 of 23 September 2013) issued by the Dominican Constitutional Court concerning Dominicans of Haitian descent, the position adopted by the Ministry of Haitians Living Abroad, Port of Prince, Oct. 24, 2013, and the statement made by the Permanent Mission of Haiti before the Organization of American States on Oct. 29, 2013. 367. Id. 369. See INA §§ 301 and 309 (acquisition of U.S. nationality by children born abroad to one or both American parents). INA § 349 provides for expatriation of citizens by birth by voluntary commission of expatriating acts committed with the intention of relinquishing citizenship. See also United States Department of State, Office of the Legal Advisor, Digest of United States Practice in International Law, Chapter 1: Nationality, Citizenship, and Immigration. However, the Supreme Court has severely curtailed the use of this measure. Afroyim v. Rusk, 387 U.S. 253 (1967). 370. U.S. Const. art. II § 1; id. at amend. XII. 360. Constitution of India, art.9 (1950), https://www. india.gov.in/sites/upload_files/npi/files/coi_part_full.pdf. 371. Schneider v. Rusk, 377 U.S. 163, 166 (1964) (quoting Osborn v. Bank of U.S., 22 U.S. (9 Wheat.) 738, 827 (1824)). 361. Citizenship Amendment Act, No. 6 of 2004, § 9; Citizenship Rules, 1956; Citizenship (Registration of Citizens and Issue of National Identity Cards) Rules, 2003 (Jan. 7, 2004), https://www.refworld.org/docid/410520784.html. 372. See generally Cassandra Burke Robertson and Irina D. Manta., (Un)Civil Denaturalization, 94 New York University Law Review 402, 437 (2019), https://www. nyulawreview.org/wp-content/uploads/2019/06/ NYULawReview-94-3-RobertsonMantapdf.pdf. 362. With regard to a seven year absence, the law stipulates that this does not apply to: a citizen who is “a student of any educational institution in a country outside India or in the service of a Government in India or of an international organisation of which India is a member, nor registered annually in the prescribed manner at an Indian consulate his intention to retain his citizenship of India.” 373. Klapprott v. United States, 335 U.S. 601, 616–20 (1949). See also Cassandra Burke Robertson and Irina D. Manta., (Un)Civil Denaturalization, 94 New York University Law Review 402, 439-43 (2019), https://www. nyulawreview.org/wp-content/uploads/2019/06/ NYULawReview-94-3-RobertsonMantapdf.pdf. 363. Michael D. Shear & Julie Hirschfeld Davis, Stoking fears, Trump defied bureaucracy to advance immigration agenda, N.Y. Times (Dec. 23, 2017), https://www.nytimes. 178 374. Knauer v. United States, 328 U.S. 654, 676 (1946). 375. United States v. Oribello Eguilos, 2019 WL 1643234, at *1-2 (E.D. Cal. Apr. 16, 2019). UNMAKING AMERICANS